Illinois, USA, Revises Law on PFAS Ban in Firefighting Foams to Include Certain Products

SG 126/25

The US state of Illinois has amended its law on intentionally added per-and polyfluoroalkyl substances (PFAS) in firefighting foams.

In 2021, Illinois approved SB 561 (Public Act (PA) 102-290, codified as 415 ILCS 170 ‘PFAS Reduction Act’) to, among other things, regulate intentionally added PFAS in Class B firefighting foams starting January 2022.

On August 15, 2025, the governor of Illinois signed HB 2516 (PA 104-0231, the Act) into law to revise the state’s PFAS Reduction Act by expanding the scope of the PFAS ban to include several product categories.

The Act introduces several terms and their definitions, including but not limited to:

• ‘Juvenile product’ – a product for use by infants and children under 12 years of age. The term includes baby and toddler foam pillows, bassinets, bedside sleepers, booster seats, changing pads, child restraint systems for use in a motor vehicle or aircraft, co-sleepers, crib mattresses, highchairs, highchair pads, infant bouncers, infant carriers, infant seats, infant sleep positioners, infant swings, infant travel beds, infant walkers, nap cots, nursing pads, nursing pillows, play mats, playpens, play yards, polyurethane foam mats, pads or pillows, portable foam nap mats, portable infant sleepers, portable hook-on chairs, soft-sided portable cribs, strollers and toddler mattresses
• This definition exempts children’s electronic products such as personal computers, audio and video equipment, calculators, wireless phones, game consoles, handheld devices incorporating a video screen or any associated peripheral such as a mouse, keyboard, power supply unit or power cord, adult mattress or a product’s internal component that does not come into direct contact with a child’s skin or mouth during reasonably foreseeable use or abuse
• ‘Product’ – an item to be sold to consumers, including its components, for personal, residential, commercial or industrial use. This term does not include:
• Prosthetic or orthotic devices, or any item classified as a medical device or drug that is otherwise used in medical settings or applications, regulated by the US Food and Drug Administration (FDA)
• Packaging for such items
• Products regulated by the Federal Insecticide, Fungicide and Rodenticide Act
• ‘Fluoropolymers’ – polymeric substances where the backbone of the polymer is either a perfluorinated or polyfluorinated carbon-only backbone or a perfluorinated polyether

Additionally, this amendment authorizes the state’s Environmental Protection Agency (EPA) to submit a report to the legislature by August 1, 2027, outlining a program to review the use of fluoropolymers in consumer products and their impacts on human health and the environment.

Highlights of the Act are summarized in Table 1.

Table 1

The Act took effect on August 15, 2025, the day it was signed into law.

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